Fraud and commercial corruption is common the world over and a particular challenge in the developing world where major consumer brands and retailers manage sourcing operations. This has enormous potential consequences to your business with risks ranging from poorly qualified suppliers entering your sourcing network, factories with egregious labor issues joining your supply chain or defective shipments passed. These outcomes have potentially disastrous consequences from the reputational damage of being linked to a tragedy, for example, to the financial consequences of a major product recall.
In Omega’s experience, the majority of brands and retailers have rudimentary risk mitigation systems. The prevalent strategy tends to be a reactive one: Investigate an allegation of corruption with summary dismissal should it be substantiated. This approach has limitations. Not only does it address the symptom rather than the cause, but, due to stringent worker protection laws, such as those in China and Vietnam (where a code of ethics may not be legally recognized), the burden of proof is stacked heavily in favor of the party laying the charge.
While there is no ‘magic bullet’, it is critical that organizations take proactive measures. While rigorous investigations should remain a cornerstone of any anti-corruption program, companies should adopt a holistic approach. Incorporating a successful, preventative program should keep good employees honest and give those more inclined towards unethical behavior pause for thought and even redress.
With unparalleled experience and expertise in managing anti-corruption programs over thousands of suppliers, Omega is uniquely qualified to help our clients anticipate, uncover and overcome a wide array of supply chain integrity challenges.
DESIGN AND IMPLEMENTATION OF ANTI-CORRUPTION PROGRAMS
As company codes of ethics become more established, associates and suppliers find new ways to circumvent the rules. It is not uncommon for associates to have a financial stake in a supplier or, in markets where credit facilities are weak, suppliers provide gray market loans. In light of these evolving challenges, it is important then that companies adopt a nuanced approach.
Omega has extensive expertise in enabling clients to institute controls across multinational supply chain operations promoting integrity and protecting their organizations. Omega is adept at developing and communicating company codes of conduct then embedding them within day to day operations across local offices not only with ‘support from the top’ but also ‘support from the middle’. Omega is expert at designing internal controls and monitoring systems to provide early warnings and prevent potential breaches.
CODE OF ETHICS TRAINING
Fundamental to a successful anti-corruption program should be regular integrity training to corporate, across local teams as well as supplier level. The purpose of the training is threefold; to introduce or elevate awareness, clarify a company’s expectations, and provide tools and resources to employees should they encounter unethical situations. Omega advocates training based on real-life scenarios, specific to each local market. What is the correct course of action should a supplier courier a set of gift vouchers to the office? Should the value of the gifts be taken into consideration? Should they be accepted, reported, rejected or any combination of the above? Also, is it permissible for an associate to purchase an item off the production floor while visiting the factory? What if he or she obtains a receipt? Are the circumstances different if the supplier has an onsite retail outlet? Associates should have a clear understanding of these nuances as well as the company’s expectations on how to report cases of attempted bribery.
With a dedicated ethical monitoring team, Omega is highly adept at conducting investigations into associates and/or suppliers aimed at identifying suspected corrupt practices such as alleged kickbacks, conflicts of interest and illicit payments. Calling upon its extensive network of resources these investigations may include research into pertinent legal representatives, reverse directorships, property holdings, litigation research, lifestyle checks, discreet interviews, inquiries and site visits.